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Justice News

Department of Justice
U.S. Attorney’s Office
Eastern District of Michigan

Friday, October 18, 2013

First Independence Bank And Federal Authorities Reach Agreement

US Attorney Barbara McQuade announced today that her office reached an agreement regarding First Independence Bank’s compliance procedures under the Bank Secrecy Act (BSA) and anti-money laundering (AML) regulations. Under the Agreement the Bank will pay a fine of $250,000 and ensure that its BSA/AML policies and procedures will comply with all applicable laws and regulations.  The Agreement requires the Bank to maintain procedures regarding customer identification and customer due diligence in order to obtain, analyze and maintain sufficient customer information to allow effective suspicious activity monitoring.  It also requires guidelines to reasonably ensure identification and timely, accurate reporting of known or suspected criminal activity as required by law.

US Attorney McQuade said that “It is vital that banks perform the required level of customer identification and due diligence and possess the ability to monitor transactions so that they can report properly to authorities when there is any suspicious criminal activity.  The banks are one of our country’s first lines of defense against, and identification of, certain financial crimes.  We are intent on vigorously enforcing their obligations to perform these obligations effectively.”

The agreement indicates that, prior to 2009, First Independence Bank had unsatisfactory BSA and AML compliance programs and practices.  US Attorney McQuade noted that, “since the time the deficiencies were discovered in 2009, First Independence has hired a significant number of new officers and staff, including in its BSA department, purchased sophisticated monitoring software, implemented several enhanced projects to identify possible money laundering in customer accounts, filed suspicious activity reports and devoted considerable resources to improved its BSA and AML compliance policies and procedures and controls.”  The Bank has agreed to maintain its systems and procedures and to comply with all applicable laws and regulations regarding AML and BSA. 

Updated March 19, 2015